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Psychology Leaders Boost Support for Senate Parity Bill
“Please help close loopholes in the current mental health parity law by cosponsoring S. 558, the Mental Health Parity Act of 2007.” Psychologist leaders took this message to their elected officials on Capitol Hill at the culmination of the APA Practice Organization 2007 State Leadership Conference (SLC), March 3-6. As a result of their meetings, psychology gained five additional Senate cosponsors for the parity bill – bringing the total number to 40 Senators.
The bill by Senators Pete Domenici (R-NM), Edward Kennedy (D-MA) and Michael Enzi (R-WY), S. 558, was approved by the Senate Health Committee on February 14 by a vote of 18 to 3. Psychology advocates expect that the full Senate will debate S. 558 after the spring recess ends in April.
The Senate bill would extend full parity protection to some 113 million Americans in group health plans covering more than 50 employees. The bill would close loopholes in the 1996 federal parity law that allow health plans to use discriminatory restrictions on mental health day and visit limits, copayments and deductibles. Further, the legislation would cover substance abuse and chemical dependency along with mental health services.
S. 558 resulted from months of compromise with representatives of the employer and insurance industries -- traditional opponents of full parity legislation. The APA Practice Organization played a key role in these negotiations, including gaining a provision in the Senate bill that would extend parity coverage to out-of-network services when a health plan provides these services.
While the employers and insurance communities favored Senate legislation that would preempt state laws, parity advocates succeeded in restricting the bill to narrow preemption of state laws.
The Senate bill does not preempt any state laws unrelated to parity or mandated mental health benefits. It does preempt provisions of state parity laws related to financial and treatment limitations such as day and visit limits, copayment and deductibles.
The bill also would apply cost exemptions. Specifically, it would provide for an exemption if employers can substantiate that their costs increased 2 percent or more in the first year, and at least 1 percent in later years, as a result of the parity law. A qualified actuary must make the determination based on actual cost data, and the exemption applies for only one year. This provision of federal law would preempt any cost exemption in state parity laws.
Significantly, the Senate bill specifically preserves the provisions of state laws that require the coverage of diagnoses. The bill language ensures that state DSM parity laws will remain in place, while state severe mental illness laws will be enhanced, since the federal law would require parity for all diagnoses covered by health plans.
SLC participants also urged Representatives to support efforts to advance parity legislation in the House of Representatives. The day after the psychology conference ended, Representatives Patrick Kennedy (D-RI) and Jim Ramstad (R-MN) introduced H.R.1424, the Paul Wellstone Mental Health and Addiction Equity Act, with a bipartisan majority of 256 cosponsors.
According to psychology advocates, the House bill differs from S. 558 in a couple of ways that employers and insurers oppose. H.R.1424 does not propose any preemption of state laws. By contrast, limited preemption is the crux of the compromise with employer and insurance representatives reflected in S. 558. Further, the House bill would mandate an out-of-network option, instead of requiring parity for out-of-network services when a health plan offers those services as well as well as in-network services.
House Speaker Nancy Pelosi (D-CA) has told Rep. Kennedy of her desire to move the bill through the three committees to which the bill has been referred. All three committees are headed by strong parity supporters. Differences in the House and Senate versions of parity legislation likely would be resolved in conference later this year.
Look for updates on the progress of 2007 parity legislation in future issues of the PracticeUpdate e-newsletter found in the “Publications and Books” section at www.APApractice.org.
NPI Update: Taxonomy Code Changes; Deciding How Many NPIs You Need
The May 23, 2007 deadline for obtaining a National Provider Identifier (NPI) is fast approaching. Psychologists need to know about several changes in the NPI “taxonomy codes” that will take effect on April 1, including the addition of a new code available to psychologists who are authorized to prescribe psychotropic medications. Further, some practitioners are unclear about whether they need to obtain one or two NPIs.
The NPI is a unique 10-digit number assigned to every health care provider or entity that applies for it. It is intended for use in identifying practitioners when they transmit information electronically – for example, in submitting claims for payment and referral authorizations.
Federal law requires all “covered entities” under the Health Insurance Portability and Accountability Act (HIPAA) to obtain an NPI. In essence, the need to comply is triggered once a practitioner transmits “protected health information” in electronic form in connection with health care claims and other transactions as specified in the HIPPA rules.
Any private health insurer can require that health care professionals who bill the insurer use an NPI, even if the billing is done by mail rather than electronically. Therefore, the APA Practice Organization encourages all psychologists who bill private and/or public health insurance plans, including federal and state programs, to obtain an NPI.
Changes in the Taxonomy Codes for Psychology Effective April 1
As part of the NPI application process, health professionals are required to list a “taxonomy code” or codes. A taxonomy code is a 10-digit alphanumeric identifier used to describe your health care practice and the services you provide.
APA was not included in the process when the psychology-related codes for the taxonomy code list were originally developed. Over the past year, the APA Practice Organization has taken its concerns about the psychology-related codes to the National Uniform Claim Committee (NUCC), the group that maintains and refines the taxonomy code set. NUCC released updates to the taxonomy code set in January 2007 that better represent how psychologists typically practice. The changes become effective on April 1.
One substantial gain by the APA Practice Organization is the addition of a new taxonomy code called “Prescribing (Medical)” for use by psychologists who are authorized to prescribe psychotropic medications. Louisiana psychologist and Committee for the Advancement of Professional Practice (CAPP) member Glenn Ally, PhD, MP, was instrumental in acquiring this new code. Also at APAPO’s urging, the NUCC is reactivating a taxonomy code for “Health” to recognize it as a developing specialty within psychology. In other changes:
- The “Neuropsychologist” code name is being changed to “Clinical Neuropsychologist.”
- Several taxonomy codes are being renamed: the “Behavioral” code will become “Cognitive and Behavioral,” the “Child, Youth and Family” code will be listed instead as “Clinical Child and Adolescent,” and “Psychotherapy, group” will be known as “Group Psychotherapy.”
- Specialty taxonomy codes for “Educational,” “Men & Masculinity,” “Psychotherapy,” and “Women” are being inactivated.
- A new definition for “Psychologist” will appear on the NPI application form.
Until the updates become effective April 1, two categories for neuropsychologist will remain on the NPI application. Any practitioner who chooses one of these codes will be reassigned to the category of “clinical neuropsychologist” in April.
To see how the psychology codes have been revised, you may visit www.wpc-edi.com/content/view/515/229. Click on “individual or groups,” then click “behavioral health & social service providers,” followed by “Psychologist” or “Clinical Neuropsychologist.” The specialties are color-coded to indicate which ones have been changed.
For any psychologist who has already obtained an NPI, please note that if you chose as your only taxonomy code one of the codes that is being inactivated, you will no longer be associated with any taxonomy code effective April 1. You can update your NPI information and include a taxonomy code by visiting https://nppes.cms.hhs.gov.
Those psychologists who want to choose “health” or “prescribing (medical)” can apply now using the general “psychologist” code and/or any other code that they feel applies to their practice, and then visit the Web site listed in the preceding paragraph beginning in April to add a “health” or “prescribing (medical)” taxonomy code.
Do I Obtain One NPI or Two?
One of the most confusing aspects of the NPI application process applies to psychologists who have their own practices. The fundamental question is: Do I need to get just one NPI for my business, or two NPIs -- one for myself as a health care provider and one for my business?
Many psychologists assume that if they obtain an NPI for their business, they can use only that NPI on their insurance claim forms, and do not need to obtain a separate NPI for themselves as individual providers. However, many payers require that all providers obtain an NPI for themselves as individuals (referred to as a type 1 NPI), even if they are in solo practice and already have an NPI for their business (referred to as a Type 2 NPI).
For example, Medicare requires that all providers obtain an individual NPI in addition to a separate NPI for their business. Many other payers are also likely to require solo practitioners to submit two NPIs on their claim forms: using the individual NPI to identify themselves as the provider who rendered the services, and the business NPI to identify their business as the billing entity. The health care claim form accepted by payers, the CMS 1500 (08/05), has been revised to include space for two NPIs.
There is an exception to this rule for sole proprietorships, which are unincorporated businesses. Such businesses do not obtain a Type 2 NPI because they are not separately incorporated entities. Sole proprietors bill all insurers using only the individual NPI (Type 1).
When applying for an individual NPI, you must use your social security number or some other form of approved identification. When applying for a business NPI, you use the business’ tax identification number. It is prudent to obtain your NPI or NPIs as soon as possible before the May 23, 2007 application deadline.
It is important to contact the payers with which you transact business about when they want you to begin using NPIs for billing purposes. At this time, many payers allow providers to submit their NPIs as well as their existing identifiers, such as the Medicare UPIN, on their health insurance claims.
Some health care professionals are likely to wait until the last minute to obtain their NPI and pass it on to payers. Instead, taking the necessary steps now may minimize disruption in your reimbursement. Payers undoubtedly will face a crunch in transferring their system of identifying health care providers to using NPIs immediately after the May 23 application deadline.
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